PLAINTIFFS' MOTION FOR ENTRY OF JUDGMENT AGAINST DURANTE & RICH REAL ESTATE, LLC

SARA L. ELLIS, District Judge.

Plaintiffs, Eric Anderson and Corrin Genovese, request that this Court enter a default judgment against defendant Durante & Rich Real Estate, LLC ("D&R"), and set a date for submission of prove-up materials and a prove-up hearing.

In support of this motion, plaintiffs state as follows:

1. On February 6, 2018, plaintiffs filed a complaint against D&R to secure redress for unlawful collection practices engaged in by defendant. Plaintiffs alleged that defendant D&R hired NCS to collect money in the amount of $3,940 for which was incorrectly charged after plaintiffs legally terminated their lease pursuant to the Chicago Residential Landlord Tenant Ordinance.

2. D&R's registered agent was served on February 16, 2018 (Exhibit A, Docket Item No. 10) D&R's answer was therefore due on March 9, 2018. As of today's date, nobody has filed an appearance on D&R's behalf, and D&R has not filed an answer to the complaint.

3. Plaintiffs alleged that defendant D&R attempted to impose an early lease termination charge on plaintiffs after they lawfully terminated their lease early pursuant to the Chicago Residential Landlord Tenant Ordinance, and then sent that amount to a collection agency, National Credit Systems, Inc. who reported it to the credit bureaus as a delinquent debt. Plaintiffs further allege that D&R did not instruct National Credit Systems, Inc. to delete the collection tradeline after plaintiffs disputed it with the credit bureaus.

4. Plaintiffs have alleged that defendant's actions violated the Fair Credit Reporting Act, and plaintiffs also seek a declaration that they do not owe D&R any money.

WHEREFORE, plaintiffs respectfully request that an entry of default be entered in favor of plaintiffs and against defendant Durante & Rich Real Estate, LLC, and that a schedule be set for submission of prove-up materials and a prove up hearing.

EXHIBIT A

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

an answer to the complaint which is herewith served upon you, 21 days after service of this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint. You must also file your answer with the Clerk of this Court within a reasonable period of time after service.